ML030340119

Application for Technical Specification (TS) Change - Missed Surveillances Using the Consolidated Line Item Improvement Process (Revision 2)

ML030340119
Person / Time
Site:	Sequoyah
Issue date:	01/29/2003
From:	Burzynski M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TVA-SQN-TS-02-04
Download: ML030340119 (17)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 January 29, 2003 10 CFR 50.90 TVA-SQN-TS-02-04 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 APPLICATION FOR TECHNICAL SPECIFICATION (TS) CHANGE - MISSED SURVEILLANCES USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (REVISION 2)

References:

1. Tennessee Valley Authority Application for Technical Specification Change - Missed Surveillances Using the Consolidated Line Item Improvement Process, Docket Nos. 50-259, 50-260, 50-296, 50-327, 50-328 and 50-391, dated September 3, 2002

2. Tennessee Valley Authority Application for Technical Specification Change - Missed Surveillances Using the Consolidated Line Item Improvement Process, Revision 1, Docket Nos. 50-327 and 50, dated October 17, 2002 The above referenced submittals provide TVA's proposed change request to modify the Surveillance Requirement Applicability for Sequoyah Nuclear Plant (SQN) Units 1 and 2 to allow a delay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the surveillance frequency interval, whichever is greater, and to require a risk analysis be performed for any surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Prinled on recycled pape,

U.S. Nuclear Regulatory Commission Page 2 January 29, 2003 Upon final review of the affected TS and Bases pages, several clerical errors were identified and a formal re-submittal of the corrected affected pages was requested in a teleconference held on January 28, 2003 with the NRC/NRR reviewer. These errors included: (1) two incidents where punctuation of TS numbers were incorrect, (2) some words were omitted in the basis section 4.0.1 where ITS wording was incorrectly incorporated, (3) an incorrect page number on a specific SON 2 page, and (4) incorrect TS number reference in the new bases control TS in which an internal section TS reference was not changed form the standard ITS TS number to the correct SON unique number.

Revised Enclosures 12 and 13 forward the corrected affected TS and Bases pages which incorporate the proposed change. These pages replace, in their entirety, pages previously submitted.

TVA has determined that these revisions do not impact the previous no significant hazards considerations or environmental review exemption transmitted in the September 3, 2002, submittal. Additionally, in accordance with 10 CFR 50.91 (b)(1),

TVA is sending a copy of this letter and enclosures to the Tennessee State Department of Public Health.

There are no commitments contained within this submittal.

If you have any questions about this change, please contact Susan Ferrell at (423) 751-7737.

Pursuant to 28 U.S.C. § 1746 (1994), I declare under penalty of perjury that the foregoing is true and correct. Executed on this 29th day of January 2003.

Sincerely, Mark J. rzynski Manager Nuclear Licensing Enclosures cc: See page 3

U.S. Nuclear Regulatory Commission Page 3 January 29, 2003 cc (Enclosures):

U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303-8931 Mr. R. K. Anand, Project Manager U.S. Nuclear Regulatory Commission MS 08G9 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, TN 37379-3624 Mr. Lawrence E. Nanney, Director TN Dept. of Environmental & Conservation Division of Radiological Health 3 rd Floor, LNC Annex 410 Church Street Nashville, Tennessee 37243-1532

ENCLOSURE 12 (Revision 2)

TENNESSEE VALLEY AUTHORITY SEQUAYOH NUCLEAR PLANT (SQN)

UNIT 1 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-02-04 REVISED PAGES AFFECTED PAGE LIST Page 3/4 0-2 Adopt NUREG 1431 Rev 2 Wording & TSTF 358 B 3/4 0-3 Adopt NUREG 1431 Rev 2 Wording B 3/4 0-3a Adopt NUREG 1431 Rev 2 Wording B 3/4 0-4 Adopt NUREG 1431 Rev 2 Wording & TSTF 358 6-11 Adopt NUREG 1431 Rev 2 Wording I1. REVISED PAGES Attached E-12-1 (6 Pages)

APPLICABILITY SURVEILLANCE REQUIREMENTS 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4 0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

4 0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4 0.2), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

4 0 4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the specified surveillance interval or as otherwise specified. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements.

4 0 5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be as follows:

Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports The program shall include the following:

a. Provisions that inservice testing of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50 55a; b The provisions of SR 4 0.2 are applicable to the frequencies for performing inservice inspection activities, c Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c.4.b of Regulatory Guide 1 14, Revision 1, August 1975 or in lieu of Position c.4.b(1) and c 4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at approximately 10-year intervals coinciding with the Inservice Inspection schedule as required by ASME Section Xl; and

d. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS SEQUOYAH - UNIT 1 3/4 0-2 Amendment No. 78, 162, 208, 274,

APPLICABILITY BASES instead, provided the other specified conditions are satisfied In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification In MODES 5 or 6, Specification 3.0 5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

3 0 6 LCO 3 0.6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS The sole purpose of this Specification is to provide an exception to LCOs 3 0 1 and 3 0 2 (e.g., to not comply with the applicable Required Action[s]) to allow the performance of SRs to demonstrate*

a The OPERABILITY of the equipment being returned to service, or b The OPERABILITY of other equipment The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system 4 0.1 SR 4.0 1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Applicability for which the requirements of the Limiting Condition for Operation apply, unless otherwise specified in the individual Surveillance Requirement The purposes of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that variables are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which associated Limiting Condition for Operation are applicable Failure to meet a Surveillance Requirement within the specified surveillance interval, in accordance with SR 4 0.2, constitutes a failure to meet a Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or b The requirements of the Surveillance(s) are known not to be met between required Surveillance performances SEOUOYAH - UNIT 1 B 3/4 0-3 Amendment No. 78,162, 202,

APPLICABILITY BASES Surveillances do not have to be performed when the unit is in an OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified.

The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply. However, the Surveillance Requirements have to be met to demonstrate that the inoperable equipment has been restored to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4 0 2. Post maintenance testing may not be possible in the current OPERATIONAL MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established. In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function This will allow operation to proceed to an OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be completed Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi. However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE. This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing b High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE. This allows operation to reach the specified pressure to complete the necessary post maintenance testing 4 0 2 Specification 4 0.2 established the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance, e.g , transient conditions or other ongoing surveillance or maintenance activities It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages The limitation of Specification 4 0 2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval 4.0 3 SR 4 0 3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limit when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4 0 2, and not at the time that the specified surveillance interval was not met SEQUOYAH - UNIT 1 B 3/4 0-3a Amendment No 78, 162, 202,

APPLICABILITY BASES This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with ACTION requirements or other remedial measures that might preclude completion of the Surveillance The basis for this delay period includes consideration of the unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements When a Surveillance with a surveillance frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, Specification 4 0 3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 4 0 3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by required ACTIONS.

Failure to comply with the specified surveillance interval for the Specification is expected to be an infrequent occurrence Use of the delay period established by Surveillance Requirement 4 0 3 is a flexibihty which is not intended to be used as an operational convenience to extend Surveillance intervals While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified surveillance interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1 182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide The risk evaluation may use quantitative, qualitative, or blended methods The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specification limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins immediately upon expiration of the delay period If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the entry into the ACTION requirements or the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the ACTIONS, restores compliance with Specification 4 0 1 SEQUOYAH - UNIT 1 B 3/4 0-4 Amendment No 78.

ADMINISTRATIVE CONTROLS Technical Specification (TS) Bases Control Program This program provides a means for processing changes to the Bases of TSs.

a Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following 1 A change in the TS incorporated in the license or 2 A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

d. Proposed changes that meet the criteria of Specification 6 8.4 j b above shall be reviewed and approved by the NRC prior to implementation Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50 71 (e) 6.9 REPORTING REQUIREMENTS ROUTINE REPORTS 6.9 1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50 4 STARTUP REPORT 6.9 1.1 DELETED 6.9 1.2 DELETED 6.9 1.3 DELETED ANNUAL REPORTS 6.9 1.4 Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March 1 of each year The initial report shall be submitted prior to March I of the year following initial criticality 6.9 1.5 Reports required on an annual basis shall include a tabulation on an annual basis for the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 mrem/yr and their associated man rem exposure according to work and job functions V reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance 1/ A single submittal may be made for a multiple unit station The submittal should combine those sections that are common to all units at the station 2/ This tabulation supplements the requirements of § 20 2206 of 10 CFR Part 20 SEQUOYAH - UNIT 1 6-11 Amendment No. 12, 32, 58, 72, 74, 148, 174,233,

ENCLOSURE 13 (Revision 2)

TENNESSEE VALLEY AUTHORITY SEQUAYOH NUCLEAR PLANT (SON)

UNIT 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-02-04 REVISED PAGES AFFECTED PAGE LIST Page 3/4 0-2 Adopt NUREG 1431 Rev 2 Wording & TSTF 358 B 3/4 0-3 Adopt NUREG 1431 Rev 2 Wording B 3/4 0-3a Adopt NUREG 1431 Rev 2 Wording B 3/4 0-4 Adopt NUREG 1431 Rev 2 Wording & TSTF 358 B 3/4 0-5 Adopt NUREG 1431 Rev 2 Wording & TSTF 358 6-7 Adopt NUREG 1431 Rev 2 Wording 6-11 Adopt NUREG 1431 Rev 2 Wording II. REVISED PAGES Attached E-13-1 (8 Pages)

APPLICABILITY SURVEILLANCE REQUIREMENTS 40 1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Specification 4.0 3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits 4.0 2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval 4.0.3 If it is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Specification 4 0.2), then compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater This delay period is permitted to allow performance of the Surveillance A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed If the Surveillance is not performed within the delay period, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered 4 0 4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the Surveillance Requirement(s) associated with the Limiting Condition for Operation have been performed within the specified surveillance interval or as otherwise specified This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements 4.0 5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components shall be applicable as follows:

Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports. The program shall include the following a Provisions that inservice testing of ASME Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50 55a, b The provisions of SR 4 0.2 are applicable to the frequencies for performing inservice inspection activities; C Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c 4 b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c.4 b(1) and c 4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at approximately 10-year intervals coinciding with the Inservice Inspection schedule as required by ASME Section XI, and d Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS SEQUOYAH - UNIT 2 3/4 0-2 Amendment Nos 69, 152, 198, 263,

BASES BASES 3 0 5 (Continued) specified conditions are satisfied In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3 0 5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to 3 0 6 LCO 3 0 6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS The sole purpose of this Specification is to provide an exception to LCOs 3 0.1 and 3 0.2 (e.g., to not comply with the applicable Required Action[s]) to allow the performance of SRs to demonstrate.

a The OPERABILITY of the equipment being returned to service; or b The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs.

This Specification does not provide time to perform any other preventive or corrective maintenance An example of demonstrating the operability of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs.

An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring during the performance of an SR on another channel in the other trip system A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system 4.0 1 SR 4.0 1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Applicability for which the requirements of the Limiting Condition for Operation apply, unless otherwise specified in the individual Surveillance Requirement The purposes of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that variables are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which associated Limiting Condition for Operation are applicable Failure to meet a Surveillance Requirement within the specified surveillance interval, in accordance with SR 4.0 2, constitutes a failure to meet a Limiting Condition for Operation Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met. Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a The systems or components are known to be inoperable, although still meeting the Surveillance Requirements, or SEQUOYAH - UNIT 2 B 3/4 0-3 Amendment No 69, 152,192,

APPLICABILITY BASES

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances Surveillances do not have to be performed when the unit is in an OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified.

The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply However, the Surveillance Requirements have to be met to demonstrate that the inoperable equipment has been restored to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 4 0.2 Post maintenance testing may not be possible in the current OPERATIONAL MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established In these situations, the equipment may be considered OPERABLE provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function This will allow operation to proceed to an OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be completed Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing b High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE This allows operation to reach the specified pressure to complete the necessary post maintenance testing 4 0 2 Specification 4.0 2 established the limit for which the specified time interval for Surveillance Requirements may be extended It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance, e g , transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4 0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval SEQUOYAH - UNIT 2 B 3/4 0-3a Amendment Nos. 69,152,192,

BASES 4.0 3 SR 4 0 3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limit when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with Specification 4 0.2, and not at the time that the specified surveillance interval was not met This delay period provides adequate time to complete Surveillances that have been missed This delay period permits the completion of a Surveillance before complying with ACTION requirements or other remedial measures that might preclude completion of the Surveillance The basis for this delay period includes consideration of the unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements When a Surveillance with a surveillance frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc ) is discovered to not have been performed when specified, Specification 4 0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

Specification 4 0 3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by required ACTIONS Failure to comply with the specified surveillance interval for the Specification is expected to be an infrequent occurrence. Use of the delay period established by Surveillance Requirement 4 0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified surveillance interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

This risk impact should be managed through the program in place to implement 10 CFR 50 65(a)(4) and its implementation guidance, NRC Regulatory Guide 1 182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide The risk evaluation may use quantitative, qualitative, or blended methods The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action All missed Surveillances will be placed in the licensee's Corrective Action Program.

SEQUOYAH - UNIT 2 B 3/4 0-4 Amendment No 69,

BASES 4.0 3 (Continued)

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specification limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the entry into the ACTION requirements or the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Allowed Outage Time of the ACTIONS, restores compliance with Specification 4 0.1 4.0 4 This specification establishes the requirement that all applicable surveillances must be met before entry into an OPERATIONAL MODE or other condition of operation specified in the Applicability statement The purpose of this specification is to ensure that system and component OPERABILITY requirements or parameter limits are met before entry into a MODE or condition for which these systems and components ensure safe operation of the facility. This provision applies to changes in OPERATIONAL MODES or other specified conditions associated with plant shutdown as well as startup Under the provisions of this specification, the applicable Surveillance Requirements must be performed within the specified surveillance interval to ensure that the Limiting Conditions for Operation are met during initial plant startup or following a plant outage When a shutdown is required to comply with ACTION requirements, the provisions of Specification 4 0.4 do not apply because this would delay placing the facility in a lower MODE of operation 4 0 5 This specification ensures that inservice inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves will be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50 55a This specification includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda This clarification is provided to ensure consistency in surveillance intervals throughout these Technical Specifications and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities Under the terms of this specification, the more restrictive requirements of the Technical Specifications take precedence over the ASME Boiler and Pressure Vessel Code and applicable Addenda For example, the requirements of Specification 4.0 4 to perform surveillance activities prior to entry into an OPERATIONAL MODE or other specified applicability condition takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows pumps to be tested up to one week after return to normal operation And for example, the Technical Specification definition of OPERABLE does not grant a grace period before a device that is not capable of performing its specified function is declared inoperable and takes precedence over the ASME Boiler and Pressure Vessel Code provision which allows a valve to be incapable of performing its specified function for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before being declared inoperable.

SEQUOYAH - UNIT 2 B 3/4 0-5 Amendment No 69, 198,

ADMINISTRATIVE CONTROLS

b. Air lock testing acceptance criteria are

1) Overall air lock leakage rate is 5 0 05 La when tested at _>Pa

2) For each door, leakage rate is *<0 01 La when pressurized to >_6 psig for at least two minutes The provisions of SR 4 0 2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 4 0.3 are applicable to the Containment Leakage Rate Testing Program Configuration Risk Management Program The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to Technical Specification structures, systems, or components for which a risk-informed allowed outage time has been granted The program shall include the following elements:

a Provisions for the control and implementation of a Level 1 at-power internal events PRA informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b. Provisions for performing an assessment prior to entering the Limiting Condition for Operation (LCO) Action for preplanned activities c Provisions for performing an assessment after entering the LCO Action for unplanned entry into the LCO Action

d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action e Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.

I Technical Specification (TS) Bases Control Program This program provides a means for processing changes to the Bases of these TSs a Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews b Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license or

2. A change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50 59.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

d. Proposed changes that meet the criteria of Specification 6.8 4 j b above shall be reviewed and approved by the NRC prior to implementation Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e)

OYAH - UNIT 2 SEQUU 6-10 Amendment No. 28. 50. 64. 66. 134. 207.22 _3.

231,

ADMINISTRATIVE CONTROLS 6 9 REPORTING REQUIREMENTS ROUTINE REPORTS 6 9.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance with 10 CFR 50.4 STARTUP REPORT 6 9.1 1 DELETED 6 9 1 2 DELETED 6 9 1 3 DELETED ANNUAL REPORTS" 6 9 1.4 Annual reports covering the activities of the unit as described below for the previous calendar year shall be submitted prior to March I of each year. The initial report shall be submitted prior to March I of the year following initial criticality.

6.9 1.5 Reports required on an annual basis shall include a tabulation on an annual basis for the number of station, utility and other personnel (including contractors) receiving exposures greater than 100 mrem/yr and their associated man rem exposure according to worK and job functions,2/ e g , reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance),

waste processing, and refueling The dose assignment to various duty functions may be estimates based on pocket dosimeter, TLD, or film badge measurements Small exposures totalling less than 20% of the individual total dose need not be accounted for In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions If the results of specific activity analysis in which the primary coolant exceeded the limits of specification 3 4 8.a, then the following information shall be included along with the results of specific activity analysis results in which the primary coolant exceeded the limits of the specifications (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded, (2) Results of the last isotopic analysis for radio-iodine performed prior to exceeding the limit, results of analysis while the limit was exceeded and results of one analysis after the radioiodine activity was reduced to less than the limit Each result should include date and time of sampling and the radioiodine concentrations, (3) Clean up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded, (4) Graph of the 1-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level, and (5) The time duration when the specific activity of the primary coolant exceeded the radioiodine limit

-!/A single submittal may be made for a multiple unit station. The submittal should combine those sections that are common to all units at the station

-2/This tabulation supplements the requirements of § 20 2206 of 10 CFR Part 20 SEQUOYAH - UNIT 2 6-11 Amendment Nos 34, 50, 66, 107, 134, 165,